Tax regime of payments made under the Guarantee Sample Clauses

Tax regime of payments made under the Guarantee. [In light of the operational arrangement described in Exhibit B to the Supplemental Indenture], income payments in respect of the Guarantee would fall under the scope of Law 10/2014 and, therefore, the tax treatment applicable will be that described in paragraph 7 above. In the event that the Notes are not listed on a regulated market, multilateral trading facility or other organized market on any Interest Payment Date (as defined in the Prospectus Supplement) or on any redemption date, Law 10/2014 will not apply to the Notes and consequently, such income payments will be subject to the tax treatment described in paragraph 8 above. However, non-Spanish tax resident beneficial owners who do not operate with respect to the Notes through a permanent establishment in Spain may take the position that income payments in respect of the Guarantee should be characterised as an indemnity under Spanish law and, hence, should have been made free of withholding or deduction on account of any Spanish tax. In such a case, these beneficial owners should apply directly to the Spanish tax authorities for any refund to which they may be entitled.